Opinion
2:21-cr-00024-APG-DJA
10-12-2022
UNITED STATES OF AMERICA, Plaintiff, v. VICTOR RAMONE WRIGHT, Defendant
JASON M. FRIERSON United States Attorney, DANIEL J. COWHIG Assistant United States Attorney RENE L. VALLADARES, Federal Public Defender, NISHA BROOKS-WHITTINGTON, Attorney for Victor Ramone Wright
JASON M. FRIERSON United States Attorney, DANIEL J. COWHIG Assistant United States Attorney
RENE L. VALLADARES, Federal Public Defender, NISHA BROOKS-WHITTINGTON, Attorney for Victor Ramone Wright
STIPULATION TO CONTINUE PRETRIAL MOTION DEADLINES (SEVENTH REQUEST)
IT IS HEREBY STIPULATED AND AGREED, by and between Jason M. Frierson, United States Attorney, and Daniel J. Cowhig, Assistant United States Attorney, and Rene L. Valladares, Federal Public Defender, and Nisha Brooks-Whittington, Assistant Federal Public Defender, counsel for Victor Ramone Wright, that the previously ordered deadline for filing of pretrial motions be vacated and that the parties herein shall have to and including November 9, 2022, within which to file the Defendant's pretrial motions previously due September 27, 2022.
IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including November 23, 2022, to file any and all responsive pleadings, currently due October 11, 2022.
IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including November 30, 2022, to file any and all replies to dispositive motions, currently due May 2, 2022.
The Stipulation is entered into for the following reasons:
1. Counsel for the defendant needs additional time to meet and discuss the government's proposed resolution with her client; and to determine whether to file a pretrial motion should her client reject the government's proposed resolution.
2. The defendant is not incarcerated and does not object to the continuance.
3. The parties agree to the continuance.
4. The additional time requested herein is not sought for purposes of delay, but merely to allow counsel for defendant sufficient time within which to discuss the proposed resolution with her client.
5. Additionally, denial of this request for continuance could result in a miscarriage of justice.
This is the seventh stipulation to continue filed herein.
FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER
FINDINGS OF FACT, CONCLUSIONS OF LAW
Based on the pending Stipulation of counsel, and good cause appearing therefore, the Court finds that:
1. Counsel for the defendant needs additional time to meet and discuss the government's proposed resolution with her client; and to determine whether to file a pretrial motion should her client reject the government's proposed resolution.
2. The defendant is not incarcerated and does not object to the continuance.
3. The parties agree to the continuance.
4. The additional time requested herein is not sought for purposes of delay, but merely to allow counsel for defendant sufficient time within which to discuss the proposed resolution with her client.
5. Additionally, denial of this request for continuance could result in a miscarriage of justice.
ORDER
IT IS THEREFORE ORDERED that the parties herein shall have to and including November 9, 2022, within which to file the Defendant's pretrial motions.
IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including November 23, 2022, to file any and all responsive pleadings.
IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including November 30, 2022, to file any and all replies to dispositive motions.